Draft a demand letter. We represent Emilio Espinosa. On May 2 nd of this year, Mr. Espinosa purchased a home from First City Bank. On that same date he purchased homeowner insurance from Capital Insurance Company. The Bank We represent Emilio Espinosa. On May and of this year, Mr. Espinosa purchased a home from First City Bank. On that same date he purchased homeowner insurance from Capital Insurance Company. The Bank had foreclosed on the home March 15, forty-eight day prior to Mr. Espinosa's purchase. Mr. Espinosa did not plan to move into the home until July 1st. On June 5, thirty-four days after Mr. Espinosa purchased the home and signed the homeowner insurance contract with Capital Insurance, copper thieves broke into the home, tore into the walls and ceiling, and stole the copper water pipes. There was extensive damage to the walls and ceiling and water damage to the carpet. The estimated cost of repairs were $19,000. The house was vacant from March 15, the date of the foreclosure until the date of the damage; a period of eighty-two days. Paragraph 20 of the insurance contract Mr. Espinosa signed with Capital Insurance excludes from coverage loss caused by "theft or attempted theft, damage by burglars,..if the described location is held as a residence and has not been occupied as a residence for more than 60 consecutive days immediately before the loss." Capital Insurance is denying coverage based upon this section of the contract. The case most on point is Pappas Enterprises, Inc. v. Commerce & Industry Insurance Co., 42 Mass. 80, 661 N.E.2d 953 (1996). With language from the case to back you up, draft a letter to Capital Insurance Company, located at 50 Sea Drive, Boston, Massachusetts 02111, demanding they pay Mr. Espinosa the full $19,000. Give them thirty days to do so, and if not, we will take legal action on his behalf